HomeMy WebLinkAbout12-7015
F \FILES\Clients\3050 Donegal\3050 Curren[\3050.6ggV050 688 complaint l.wpd l'7
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George B. Faller, Jr., Esquire ~~ .,~ `~:-=
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER ~'r
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MARTSON LAW OFFICES ' `~
I.D. 49813 ,Cp
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10 East High Street ~?
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Carlisle, PA 17013 =~ -- ~~
(717) 243-3341 _
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Attorneys for Plaintiff
DONEGAL MUTUAL INSURANCE IN THE COURT OF COMMON PLEAS OF
COMPANY, as Subrogee of MARIE CUMBERLAND COUNTY, PENNSYLVANIA
TURNER,
Plaintiff
v. NO. ~a-~7OlS l..f~(~
CIVIL ACTION -LAW
JACK C. MEREDITH,
Defendant
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so, the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiffs. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCE FEE OR NO FEE:
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
~~-- acs 3~
~~ a$sa3(,
George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 49813
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DONEGAL MUTUAL INSURANCE IN THE COURT OF COMMON PLEAS OF
COMPANY, as Subrogee of MARIE CUMBERLAND COUNTY, PENNSYLVANIA
TURNER,
Plaintiff
v. NO.
CIVIL ACTION -LAW
JACK C. MEREDITH,
Defendant
COMPLAINT
1. Plaintiff, Donegal Mutual Insurance Company ("Plaintiff'), is an insurance company
licensed to do business in Pennsylvania with an address of 1195 River Road, Marietta, Pennsylvania
17547-0302.
2. Defendant, Jack C. Meredith ("Defendant"), is an adult individual with a last known
address of 1592 Pin Oak Drive, Chambersburg, Pennsylvania 17201.
3. On or about June 8, 2012, Marie Turner was operating a 2005 Honda Accord at or
near the intersection of Orchard Drive and Mill Road in Chambersburg, Pennsylvania. She stopped
her vehicle at a stop sign at or near this intersection. Defendant was operating a 1998 Chevrolet 5-10
at or near the same intersection at approximately the same time. Defendant failed to slow down
when approaching the stop sign at or near this intersection.
5. As a result of Defendant's failure to slow his vehicle, Defendant's vehicle struck the
rear end of Joshua Rosenberry's 1996 Ford. Joshua Rosenberry's vehicle was pushed forward by
the impact, which caused his vehicle to strike the rear end of Marie Turner's vehicle while she was
stopped at the stop sign.
6. Defendant was operating his vehicle with a suspended license at the time of this
collision. Police were called to the scene and Defendant was arrested.
6. Defendant's insurance company, Infinity Insurance, denied him coverage because he
was driving with a suspended license at the time of the collision.
7. The collision was caused as a result of the negligence, recklessness and carelessness
of Defendant in that he:
a. Failed to properly stop at the stop sign;
b. Failed to operate his vehicle in a manner to avoid causing a chain event that
damaged Marie Turner's vehicle when she was properly stopped at the stop sign; and
c. Operated a vehicle on a suspended driver's license.
8. Pursuant to the insurance policy contract, Plaintiff is entitled to claim and pursue
subrogation rights against third parties responsible for losses paid out under said contract.
9. As a result of the collision, Marie Turner's vehicle was damaged in the amount of
$3,711.01. A copy of the repair estimate is attached hereto as Exhibit "A."
10. As a result of the collision, Plaintiff was required to pay Marie Turner for damages
in the amount of $3,711.01.
11. Plaintiff is subrogated to all of the rights of Marie Turner resulting from the collision
on June 8, 2012.
12. The outstanding balance owed by Defendant is $3,711.01, for which the claim is
made by Plaintiff as subrogee.
WHEREFORE, Plaintiff demands judgment against Defendant in the amount of $3,711.01,
plus costs, interest, and any other relief that the court deems appropriate.
Respectfully submitted,
By
MARTS
W OFFICES
George B. Fa11~r, ~
I.D. No. 49813
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Date: ~~ ~/(c f f ~ Attorneys for Plaintiff
DONEGAL INSURANCE GROUP
1195 RIVER ROAD P.O. BOX 302
MARIETTA, PA 17547-0302
(717) 426-1931 FAX: (717) 426-7023
**` ESTIMATE *'"
06/18/2012 01:20 PM
Owner
Owner: MARIE TURNER
Address: 193 MILL RD Home/Day: (717)504-8458
City State Zip: CHAMBERSBURG, PA 17201 FAX:
Controllntormation
.......................................................................................................................................................................................................
.....................................1
Claim # : PAF-PA-01-12-0269600
Loss DatelTime: 06/08/201208:00 AM
Deductible: $250.00
File #
Ins. Company: Donegal Insurance Group
Addross:
City State Zip:
Agent: Debra Jones
Address:
Email: debrajones~donegalgroup.com
Insured: MARIE TURNER
Address:
Claim Rep: Debra Jones
Address:
Email: debrajones c@donegalgroup.com
Insured Policy # : PAF-3112162
Loss Type: Collision
Accounting # : 0004105
Cell: (717)479-3429
Wotic/Day: (717)885-0317
FAX: (717)885-0319
Work/Day: (800}877-0600x7435
Home/Day: (717)504-8458
Work/Day: (800)877-0600x7435
...ins~sction y~.w...v....._.M............~.,~.._k_..~.....~...~....~,...............~..~.....,.... .~,.....~.-.........,r..~-,...~.,......w.,,...~.....~
° In"s~sctlon Date:
Inspection Location:
Address:
City Stab Zip:
Primary Impact:
Driveabb:
06/18/2012 01:19 PM
Antrim Honda
Inspection Type: Field
Contact:
Home/Day: (717}504$458x
Greencastle, PA 17225
Rear
Yes
Assigned Dab/Time:
First Contact Dab/Time:
Company:
Contact:
Address:
BRETT SOWERS
City Stab Zip:
Email: brettsowers@donegalgroup.com
Secondary Impact:
Rental Assisted:
Received Date/Time: 06/18/2012 09:17 AM
AppoiMrrront Dats/Time: 06/18/2012 08:00 AM
Appraiser License # : 137401
Work/Day: (717)885-0317
Cell: (717)479-3429
FAX: (717)885-0319
,.,...,....,,. .,,.,.,.,,~,,,,,..,..,,,,,,,,..,..,,,,,,,,,,,,,,,,,,,,,,,,,.,,,,..,..,..,,,,,,,4
Address: Home/Day: (717)504-8458
City Stab Zip: Greencastle, PA 17225 FAX:
08l18/2p12 Oi :30 PM Pie t of 8
Exhibit "A"
?005 Honda Aaord LX 4 DR Sedan G6l18l2012 01:20 PM
Claim # : P'AF•PA-01-12-0269600
Target Complete Date/Time: Days To Repair: 7
. Remartcs__.~ ..............k~.......~..,.......~...+....~.......,,,..,~.,,..,,.,..~........,.~....~...,~,...,..,~........,....,,.y. Y..r..,...,,,..,.~,,.....,..,...~...,_~..,-..-........,~.w..y...m
.........a
ALL SUPPLEMENTS DAMAGE MUST BE APPROVED BY THE APPRAISER
-SUPPLEMENTS MUST INCLUDE -ALL INVOICES- &SIGNED DIRECTION OF PAY FOR PAYMENT
COPY 01~ t71!4iA'CE~VIl7~:~7 ~iQ1~ 0e~i'i~C1 ~`
Vehicle
2005 Honda Accord LX 4 DR Sedan
4cyl Gasoline 2.4 VTEC
5 Speed Automatic
LiC.Plate: HJE7156 Lic State: PA
Lic Expire: VIN: 3HGCM56415G705869
Prod DaM: 02/2005 Mileage: 66,610
Veh Inspd : Mileage Type: Actual
CondRion: Code: H12838
Ext. Cobr: beige InL Color:
Ext. Refinish: Two-Stage Int. Refinish:
Options
AM/FM CD Player Air Conditbning Alarm System
Anti-kx~c Brakes Bucket Seats Center Console
Cruise Control Dual Airbags Head Airbags
Intermittent Wipers Keyless Entry System Lighted Entry System
Overhead Console Power Brakes Power Door Locks
Power Mirrors Power Steering Power Windows
Rear Window Defroster Rem Trunk-UGate Release Side Airbags
Tachometer Telescopic Steering Whl Tilt Steering Wheel
Tinted Glass Velour/Cloth Seats
...Dame~esµ..~..~..~......~..,,.~......w....,,.,.u~ ..............................~...~,,.....,...~.,.,....,....._.._.....w.~...~....,~~ w.....,....._.,.......,,.....,_._.,......
L1ne Op Gufde MC Descrlptbn MFR.Part No. Prk:e ADJ% B% Hours R
1 L 189 Pillar,Center LT Refinish 1.0 RF
1.0 Surface
2 L 190 PIIIar,Center RT Refinish 1.0 RF
1.0 Surface
» BLEND ABOVE DOORS
3 RI 351 MIdg,Roof Drfp LT R & I Assembly 0.5 SM
4 RI 352 MIdg,Roof Drip RT R & I Assembly 0.5 SM
5 I 369 Bads Glass,Heated Repair 0.3' SM
6 I 389 Panel,C:uarter LT Repair 0.5' SM
7 L 389 13 Panel,Quarter LT Refinish 4.0 RF
2.8 Surface
0.6 Two-stage setup
0.6 Two-stage
8 I 390 Panel,Quarter RT Repair 2.0' SM
9 L 390 Panel,Quarter RT Refinish 3.0 RF
2.5 Surface
0.5 Two-stage
10 BR 397 Door,Fuel Filler LT Blend Refinish 0.2 RF
0.1 Blend
0.1 Two-stage
11 I 443 Gutter,Deck Lid RT Repair 2.0' SM
08/16!2012 01:30 PM
Pape 2 of 8
2005 Honda Accord LX 4 DR Sedan
Gaimi<: PAF-PA-01-12.0289600 06118/2012 01:20 PM
12 L 443 Gutter,Deck Lid RT Refinish 0.2 RF
0.2 Surface
13 EU 479 Deck Lid Assembly LIKE KIND & QUAL.PRT $450.00' +25.00 0.9 SM
» LKG1250 800-334-9811 X4786; QUOTE 1174239
14 L 479 Lid,Rear Deck Refinish 3.4 RF
2.0 Surface
1.0 Edge
0.4 Two-stage
15 RI 391 Pnl,Lid Inner Trim R & I Assembly 0.2 SM
16 E 519 N/Plate,Deck Lid 75722SDAA00 $17.12 0.2 SM
17 E 521 N/Plate,Deck Lid 75731 S84A00 $10.80 0.1 SM
18 E 507 Emblem,DedcLid 75701SDA000 $18.08 0.2 SM
19 RI 487 Lock,Deck Lid R & I Assembly 0.2 SM
20 RI 518 Spoller,Dedc Lid R ~ I Assembly 0.5 SM
21 E 509 Panel Assy,Rear Body 66100SDAAOOZZ $316.73 7.4 SM
22 L 509 Panel Assy,Rear Body Refinish 2.0 RF
1.5 Surface
0.5 Edge
23 EU 536 Taillamp Assembiy,lnr RT R & I Assembly $0.00' 0.3 SM
24 RI 533 Lens,Taillamp Outer LT R & I Assemby INC SM
25 EU 534 Lens,Taiilamp Outer RT LIKE KIND 8 GIUALPRT $75.00' +25.00 INC SM
26 PC 950 Cover,Rear Bumper Replace PXN Reconditbned $305.00 0.6 SM
27 L 950 Cover,Rear Bumper Refinish 3.2 RF
2.7 Surtace
0.5 Two-stage
28 N Flex AdditNe Additional Labor $8.00' SM
29 EC Cover Car Exterbr Replace Economy $5.00' SM
30 1 Pinstripes-Tape Sublet Repair $15.00' 0.3' SM
31 N DISABLE BATTERY Additional Labor 0.1' SM
32 N Corrosion Protection Additbnal Labor $10.00' 0.3' SM
33 N Hazardous Waste Removal Additional Labor $3.00' SM
34 I PULL REAR BODY Repair 1.0' SM'
35 EC SEAM SEALER Replace Economy $47.58' SM'
36 RI MUDFLAPS R & I Assembly 0.3' SM`
36 Items
MC Message
13 INCLUDES 0.6 HOURS FIRST PANEL TWO-STAGE ALLOWANCE
4 Estimate Total il< Entriea..,,.,,,,.,...,,,,,,,,,,,,,,,,...,,w,...,,...., .,...,,..M.-...,,,.,,.,,.,.,,,,.,,..,,.. ...... '
Gross Parts $362.73
Other Parts $903.58
Paint Materials $414.00
Line Item Markup $131.25
Parts de Material Total $1,811.56
Tax on Parts & Material @ 6.000% $108.69
Labor Rate Replace Repair Hrs Total Hrs
Hrs
Sheet Metal (SM) $46.00 11.9 6.5 18.4 $848.40
Mach/Elec (ME) $47.00
Frame (FR) $48.00
Reflniah (RF) $46.00 18.0 18.0 $828.00
Paint Materials $23.00
Labor Total 36.4 Hours $1,674.40
Tax on Labor Cap 6.000ga $100.46
Sublet Repairs $15.00
Tax on Sublet CaD 6.000% $0.90
Gross Total $3,711.01
0&1812012 0130 PM Pape 3 0( 8
2005 Honda Accord LX 4 DH sedan
.. n nn M
06/18/2012 01:20 PM
Less: Deductible $250.00-
Net Total $3,461.01
Alternate Parts Y/01/01/00/00/00 CUM 01/01/00/00/00 Zip Code: 17368 YORK
Audatex Estimating 6.0.726 ES 06/18/2012 01:30 PM REL 6.0.726 DT 06/01/2012 DB 06/15/2012
CopyNght (C) 2011 Audatex North AmsNca, Ina
2.7 HRS WERE ADDED TO THIS ESTIIiAATE BASED ON AUDATEX'S TWO-STAC3E REFlNISH FORMULA.
ABBREVIATION LEGEND:
LKQ = LIKE KIND IN QUALITY, A/M = AFTERMARKET, RECOND = RECONDITION, 0/H=
OVERHAUL, REPL = REPLACE, RPR = REPAIR, REFN = REFINISH, SECT = SECTION,
R & I = REMOVE AND INSTALL, ALGN = ALIGN, SUBL = SUBLET, BLND = BLEND, ASSY=
ASSEMBLY, FRNT/FRT = FRONT, HL/H/LAMP = HEADLAMP, INR = INNER, L = LEFT,
MLD/MLDG = MOLDING, MTG = MOUNTING, OTR = OUTER, PNLS = PANELS, R/RT = RIGHT,
REPL = REPLACEMENT, SUSP = SUSPENSION, W/O MLD = WHEEL OPENING MOLDING, RIC =
REMOTE CONTROL, BRKT = BRACKET, LIC = LICENSE, R/F = RIGHT FRONT, R/R = RIGHT
REAR, L/F = LEFT FRONT, L/R = LEFT REAR, PNL = PANEL, FT = FRONT, PXN =
PARTS EXCHANGE NEW, OEM = ORIGINAL EQUIPMENT MANUFACTURER, PRT = PART, NAGS =
NATIONAL ASSOCIATION OF GLASS SUPPLIER, REMAN = REMANUFACTURED, PART = PARTIAL
ANY PERSON WHO KNOWINGLY AND WITH INTENT TO DEFRAUD ANY INSURANCE COMPANY OR
OTHER PERSON FILES AN APPLICATION FOR INSURANCE OR STATEMENT OF CLAIM
CONTAINING ANY MATERIALLY FALSE INFORMATION OR CONCEALS FOR THE PURPOSE OF
MISLEADING, INFORMATION CONCERNING ANY FACT MATERIAL THERETO COMMITS A
FRAUDULENT INSURANCE ACT, WHICH ZS A CRIME AND SUBJECTS SUCH PERSON TO
CRIMINAL AND CIVIL PENALTIES.
WE WILL NOT BE RESPONSIBLE FOR ANY RELATED TOWING SERVICES OR STORAGE CHARGES,
KNOWN AT THE TIME OF THE APPRAISAL, AND INCURRED AFTER THE FOLLOWING
DATE: .......... CHARGES INCURRED AFTER THIS DATE WILL BE THE RESPONSIBILITY
OF THE CONSUMER.
COSTS THAT EXCEED THE APPRAISED AMOUNT MAY BE THE RESPONSIBILITY OF THE
VEHICLE OWNER.
IF YOU REQUEST, WE CAN PROVIDE YOU WITH THE NAMES OF REPAIR FACILITIES THAT
WILL BE ABLE TO REPAIR THE VEHICLE FOR THE APPRAISED AMOUNT. THERE IS NO
REQUIREMENT TO USE ANY SPECIFIED REPAIR SHOP.
THIS IS NOT AN AUTHORIZATION TO REPAIR. NO SUPPLEMENTS HONORED UNLESS
INSPECTED AND AUTHORIZED BY APPRAISER. IF THE APPRAISAL INCLUDES AFTERMARKET
CRASH PARTS, THE AFTERMARKET CRASH PART SHALL HAVE A WARRANTY EQUAL TO OR
BETTER THAN THE REMAINDER OF THE EXISTING WARRANTY ON THE PART BEING REPLACED.
06/18/2012 0130 PM Pape 4018
2005 Honca AcCoM lX 4 DR Sedan 06J18l2012 01:20 PM
CI3im a : PAF-PA-01.12.0289800
APPRAISER SIGNATURE:
Op Codes
' =User-Entered Value
EC =Replace Economy
ET =Partial Replace Labor
TE =Partial Replace Price
L =Reflnish
TT =Two-Tone
BR =Blend Reflnish
CG= Chipguard
AA =Appearance Allowance
E =Replace OEM
OE= Replace PXN OE Srpis
EP =Replace PXN
PM= Replace PXN RemaNReblt
PC =Replace PXN Recondftloned
SB =Sublet Repair
I =Repair
RI = R 8 I Assembly
RP = Related Prbr Damage
NG = Replace NAGS
UE =Replace OE Surplus
EU =LIKE KIND 8 QUAL.PRT
UM= Replace RemaNRebuilt
UC =Replace Reoonditbned
N =Additional Labor
IT ;Partial Repair
P =Check
This report contains proprietary informatbn of Audatex and may not be disclosed to any third party (other than
the insured, claimant and others on a need to know balls in order to effectuate the claims process) without
~~~~~ Audatex's prior written consent.
~ s~errca dA.»yhin]~
~ •~~-----~»»N~Copyright (C) 2011 Audatex North America, tnc.
Audatex Estimating is a trademark of Audatex North America, Inc.
08718f2012 01:30 PM
Pape 5 of 8
C611&201201:20 PM
20p$ Honda Accord lX 4 t3Fl Sedan
Claim n : PAP-PA-01.12-0269600
Estimate Summary Page
Gross Total $3,711.01
Less: Deductible $250.00-
$3,461.01
Net Total
Audatex Estimating 6.0.726 ES 06/18/2012 01:30 PM REL 6.0.726 DT 06/01!2012 DB 06/15/2012
Copyright (C) 2011 Audatex North America, inc.
Pape 8 of 8
08l18lZ012 01:30 PM
Audatex Alternate Parts Locate Report
Uehbte
2005 Honda Accord LX 4 DR Sedan ~ -. ~ ~-~~
4cyl Gasoline 2.4 VTEC
5 Speed Automatic
Options
AM/FM CD Player
Ami-bdc Brakes
Cruise Comrol
Intermittent Wipers
Overhead Consde
Power M~rors
Beer Window Defroster
TacFlomeler
Tinted Glass
Llns Part Descrfpdon
28 Cover,Rear Bumper
H01100208R 04715SDAA90ZZ > 1 R 3
> .ESTIMATE TOTAL IS BASED ON PRICE OUOTED BY THIS SUPPLIER
........... .. .. . .. ...... ..... .. . ..... .... .... .. .. ... .. ... . . ..... ... ... .... . ....... ... . ....... .. .. . .. ... ... . ...... ... . .. .. . . . .. .. . .. . .
. .. .. .... .. . . ... .. .. .... .. ... .. . ..... . . .... . . . ... ..... ... .............. ... . .. .... .. .. ....... :
~t(ey to Clasaiflcatla+ I Source Codes i
CLS = Classtfk~tlon Code
C - CAPA CERTIFIED PART OUOTED BY LISTED SUPPLIER
M - REMANUFACTURED /REBUILT PART
R -RECONDITIONED PART
S -OEM SURPLUS PART
SRC .Source Cale
1 -NON ORIGINAL EOUIPMENT MANUFACTURER PART
3 -ORIGINAL EQUIPMENT MANUFACTURER (OEM) PART
Dlabibutor Lint
Air Conditioning
Bucket seats
Dual Airbags
Keyless Entry System
Power Brakes
Power Steering
Rem Trunk-L/Gate Release
Telescopic Steering Whl
VeloudCbth Seals
Supplkr Part Number ~ ~ ~~0~ Supplbr Code CLS SRC
Alarm System
Cemer Console
Head Airbags
UgMed Emry System
Power Door Locks
Power Windows
Side Airbags
Tilt Steering Wheel
PXN5025
KEYSTONE AUTO RCND
275 CROSS FARM LANE
YORK, PA 17408
(800)524.4349
(717)s43-8927
Audatex Estimating 6.0.726 ES 06118!2012 01:30 PM REL 8.0.726 DT 0 6/01120 1 2 DB 06/15!2012
Zip Code: 17388 Search Ares:
CopyrlgM (C) 2011 Audatex North America, Inc.
YORK
This report contains proprietary informatbn of Audatex and may riot be disdosed to any third pa-iy (other than the
insured, claimam and others on a need to know basis in order to effectuate the claims process) without Audatex's
~~~'~~ prior written consent.
'~ '~`a~`~'''`v'"~°~r.~,,,,, Copyright (C) 2011 Audatsx North Amerirar, Inc.
Audatex Estimaiin is a trademark of Audatex North Ame ' Inc.
06/18/2012 01:30 PM Page i of 1
. ~ ~
VERIFICATION
I, Tamara L. Richardson ,Subrogation Claims Rep. of Donegal Mutual
Insurance Company, acknowledge I have the authority to execute this Verification on behalf of
Donegal Mutual Insurance Company and certify the foregoing Complaint is based upon information
which has been gathered by my counsel in the preparation of the lawsuit. The language of this
Complain is that of counsel and not my own. I have read the document and to the extent the
Complaint is based upon information which I have given to my counsel, it is true and correct to the
best of my knowledge, information and belief. To the extent the content of the Complaint is that of
counsel, I have relied upon counsel in making this Verification.
This statement and Verification are made subject to the penalties of 18 Pa. C.S. § 4904 relating
to unsworn falsification to authorities, which provides that if I knowingly make false averments, I
may be subject to criminal penalties.
DONEGAL MUTUAL INSURANCE COMPANY
F\FILES\Clients\3050 Donegal\3050 CurrentU 050.688\3050 688 complaintl.wpd
F:\FILES\Clients\3050 Donegal\3050 Current\3050.688\3050.688.pra2.wpd
THE PROTHONOTt�,E�s:;
George B. Faller, Jr., Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 2014 JAN 28 AH * b 3
MARTSON LAW OFFICES CUMBERLAND COUNT i,
I.D. 49813 PENNSYLVANIA
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Plaintiff
DONEGAL MUTUAL INSURANCE IN THE COURT OF COMMON PLEAS OF
COMPANY, as Subrogee of MARIE CUMBERLAND COUNTY, PENNSYLVANIA
TURNER,
Plaintiff
V. NO. 12-7015
JACK C. MEREDITH, CIVIL ACTION - LAW
Defendant
PRAECIPE TO SATISFY THE JUDGMENT
TO THE CUMBERLAND COUNTY PROTHONOTARY:
Please mark the default judgment against Jack C. Meredith in the above-captioned action as
satisfied and the matter discontinued.
MARTSON LAW OFFICES
By
q��� , 6.4N
George B. Illaller, Jr., Esquire
I.D. No. 49813
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 1/28/14 Attorneys for Plaintiff
s-9,
a
CERTIFICATE OF SERVICE
I,Nichole L. Myers, an authorized agent of MARTSON LAW OFFICES hereby certify that
a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at
Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Mr. Jack C. Meredith
1592 Pin Oak Drive
Chambersburg, PA 17202
MARTSON LAW OFFICES
By
Nichole L. Myers
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: 1/28/14